Last updated : 5 September 2026
AI Chat Innovators Ltd (“we”, “us”) provides an HR‑Coaching SaaS platform on behalf of your employer 'Avertri'. Your employer is the controller of your personal data; we act only as their processor.
1 · What data we process
| Category | Examples | Purpose | Legal basis (UK GDPR) | Retention* |
|---|---|---|---|---|
| Account data | Name, corporate e‑mail | Create & secure your account | Contract Art 6(1)(b) | Deleted immediately when your employer removes your profile; encrypted backups rotate after 7 days |
| Profile photographs and uploaded images | Images you or a permitted manager upload, together with technical details such as file type, size and storage reference | Display an authorised profile photograph and provide image features enabled by your employer Profile images are validated, resized, converted to a standard format and stripped of unnecessary source metadata before storage. |
As determined and communicated by your employer as data controller | Deleted when replaced or when your employer removes your profile, subject to your employer's documented retention instructions; temporary migration copies are retained only for the documented migration verification period |
| Usage logs | Timestamps, feature clicks, IP, user‑agent | Troubleshooting & security audit | Legitimate interest Art 6(1)(f) | 90 days · extended to 12 months if investigating an incident |
| AI interaction answers | Responses you click “Save answer” on | Provide historical coaching context | Contract Art 6(1)(b) | Deleted immediately when your employer removes your profile; encrypted backups rotate after 7 days |
| AI interaction questions | Text you type to the coach | Generate live coaching response via OpenAI API Prompts are not used to train or improve OpenAI models. |
Contract Art 6(1)(b) | ≤ 30 days at OpenAI (encrypted abuse‑monitoring logs)† |
| Coaching profile assessments | Communication and information-format preferences, public-domain IPIP-50 workplace behaviour responses and results, your confirmed summaries and optional notes | Personalise workplace coaching and, where you enable sharing, help permitted managers adapt communication and development support Individual questionnaire answers and numerical results are not shown to managers. Sensitive behavioural results are excluded from manager summaries, and profiles are not used for automated employment decisions. |
As determined and communicated by your employer as data controller | Deleted when your employer removes your profile, subject to your employer's documented retention instructions; encrypted backups rotate after 7 days |
*Retention periods may be shortened or extended at your employer’s written instruction.
† Deleted sooner if we activate OpenAI’s Zero‑Data‑Retention option.
2 · Sub‑processors
| Provider | Service / purpose | Region / retention & safeguards |
|---|---|---|
| Render .com | Primary application & PostgreSQL database hosting | DE (Frankfurt) – data remain in EEA; daily encrypted backups 14 days |
| Render Global CDN | Edge delivery of static assets | Worldwide edge cache, objects expire < 24 h; origin Frankfurt (EEA) |
| Cloudflare, Inc. (R2) | Private object storage and secure delivery of profile photographs and other enabled user-uploaded images | Object storage restricted to the EU jurisdiction; objects and metadata encrypted at rest using AES-256 and protected in transit using TLS; access provided through short-lived signed links; contractual safeguards include Cloudflare's Data Processing Addendum and applicable transfer clauses |
| OpenAI (EU endpoints) | AI model inference for coaching responses | IE (Dublin) – EEA; abuse‑monitoring logs ≤ 30 days (0 days if ZDR); no model‑training; SOC 2; SCCs |
3 · Security measures
- Encryption in transit – All external connections to our platform are protected using TLS 1.2 or above.
- Encryption at rest – Data is hosted on Render.com’s managed services, which apply AES‑256 encryption to databases and backups.
- Private image storage – User-uploaded images are stored in a private Cloudflare R2 bucket restricted to the EU jurisdiction and encrypted at rest using AES-256. Storage credentials are restricted and kept outside the application source code.
- Temporary image access – Permitted users receive short-lived signed image links after Avertri applies its existing profile visibility rules. The storage bucket is not made public.
- Safer image processing – Profile photographs are decoded, size-limited, resized, converted and stripped of unnecessary source metadata before being stored.
- Access control – Access to the platform is protected using secure password authentication and JWT-based session tokens. Roles are used to restrict access by user type.
- CSRF protection – Authenticated sessions include CSRF tokens to prevent cross-site request forgery attacks.
- Infrastructure monitoring – Our hosting provider (Render.com) monitors for platform-level threats and applies rate-limiting to protect against abuse.
- Pseudonymisation for AI prompts – When generating coaching responses, employee names are replaced with hashed aliases to minimise exposure of identifiable information.
4 · International transfers
The primary application and database are hosted in Germany. User-uploaded image objects are stored and processed in Cloudflare R2's EU jurisdiction. Cloud service suppliers and their approved sub-processors may nevertheless involve access or processing outside the UK. Where a restricted transfer occurs, it is protected by applicable adequacy arrangements, Standard Contractual Clauses, the UK Addendum or another lawful transfer mechanism.
5 · Your rights
You have the right to access, rectify, erase, restrict or object to processing, and to data portability. Please contact your employer’s HR team to exercise these rights; we will assist them promptly.
6 · Complaints
You may lodge a complaint with the UK Information Commissioner’s Office
7 · Automated decision‑making
We do not make decisions that produce legal or similarly significant effects based solely on automated processing.
8 · Contact
Data Protection Officer — dpo@aichatinnovators.com